Website: https://www.globalreporting.org/
Email: gssbsecretariat@globalreporting.org

Item 03 - GRI Topic Standard Projectfor Biodiversity– Draft GSSB basis forconclusions for GRI 101: Biodiversity

2024
For GSSB review and discussion
Date

30 November 2023

Meeting

14 December 2023

Project

GRI Topic Standard Project for Biodiversity

Description

This document summarizes the significant issues raised by comments received on
the GRI Biodiversity Standard exposure draft, during the public comment periods
from 5 December 2022 to 28 February 2023, and from 26 July to 10 September
2023. This document outlines the responses from the Global Sustainability
Standards Board (GSSB) to the significant issues raised based on discussions
and recommendations by the Biodiversity Technical Committee.
The GRI Biodiversity Standard exposure draft was open for public comments from
5 December 2022 to 28 February 2023. Due to the nature of feedback received onDisclosure 304-7 Access and benefit-sharing, and the resulting changes made tothis disclosure, the GSSB decided to publish Disclosure 304-7 Access andbenefit-sharing for a second public comment period from 26 July to 10 September
2023.
The GRI Standards Division has prepared this draft, which will be updated, as
needed, based on GSSB feedback to the final Standard. The draft is circulated for
the GSSB for review and discussion. A final version of this document will be
released following the approval of GRI 101: Biodiversity 2024.
As outlined in the Due Process Protocol, this document is not subject to voting
approval, does not constitute part of the final Standard, and is non-authoritative.
The full set of public comments can be downloaded from the Topic Standard
Project for Biodiversity page on the GSSB website.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. The
GSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2023

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Contents2

About this document ............................................................................................................................... 33

Introduction.............................................................................................................................................. 3

4

Objectives for revising GRI 304: Biodiversity 2016 ................................................................................. 3

5

Scope of the public comment .................................................................................................................. 4

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Overview of participation in public comment........................................................................................... 4

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Methodology for analyzing comments .................................................................................................... 5

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Significant issues and GSSB responses ................................................................................................. 6

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Cross-cutting issues ................................................................................................................................ 6

10

Issues by disclosure ................................................................................................................................ 81112Disclosure 304-1 Location of operational sites with the most significant impacts (Disclosures 101-4
and 101-5 in the final Standard) .............................................................................................................. 813

Disclosure 304-2 Direct drivers of biodiversity loss (Disclosure 101-6 in the final Standard) ................ 914

Disclosure 304-3 State of biodiversity (Disclosure 101-7 in the final Standard) ................................... 11

15

Disclosure 304-4 Ecosystem services (Disclosure 101-8 in the final Standard) .................................. 1216
17

Disclosure 304-5 Management of biodiversity-related impacts (Disclosure 101-2 in the final Standard).............................................................................................................................................................. 1318
19

Disclosure 304-6 Halting and reversing the loss of biodiversity (Disclosure 101-1 in the final Standard).............................................................................................................................................................. 15

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Disclosure 304-7 Access and benefit-sharing (Disclosure 101-3 in the final Standard) ....................... 15

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Summary of public comments on the second exposure draft of the Standard, and GSSB responses 16

22

Appendix 1. Participation to regional events and webinars .................................................................. 17

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Appendix 2. Public comment submissions by stakeholder constituency, and region ........................... 18

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About this document

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This document summarizes the significant issues raised by respondents regarding the GRI
Biodiversity Standard exposure draft during the public comment periods from 5 December 2022 to 28
February 2023, and from 26 July to 10 September 2023.

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The document includes the feedback provided by respondents through the public comment survey
hosted on the Topic Standard Project for Biodiversity page and the feedback submitted by email.

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All individual comments received, together with an analysis of the significant issues raised, wereconsidered by the Global Sustainability Standards Board (GSSB) in their revision of the Biodiversity
Standard. This document provides a summary of how the GSSB has responded to the significant
issues raised in the public comment period.

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The full set of comments received can be downloaded from the Topic Standard Project for
Biodiversity page on the GSSB website.

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GRI 101: Biodiversity 2024 can be downloaded [here].

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Introduction

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Objectives for revising GRI 304: Biodiversity 2016

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The project proposal for the review of GRI 304: Biodiversity 2016 was approved by the Global
Sustainability Standards Board (GSSB), GRI’s independent standard setting body, at its meeting on
29 September 2021. The primary objective of the project was to review the GRI 304 to representinternationally agreed best practice and align with recent developments and the relevant authoritativeintergovernmental instruments in the field of biodiversity.

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The project followed the GSSB Due Process Protocol. A multi-stakeholder technical committee of 18
experts representing all five GRI constituencies was appointed by the GSSB in November 2021. The
technical committee informed the revision of the Standard by convening throughout 2021-2023 in 10
meetings.

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The following specific objectives were established by the GSSB when commencing the revision of theStandard, and were considered throughout the project:

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revising the existing ‘Background context’ information within GRI 304;
developing the topic management disclosures, considering contents in the existing
management disclosures section within GRI 304, including:o developing new requirements, recommendations, and guidance.
ensuring that the revised management disclosures are compatible for organizations to use
together with GRI 3: Material Topics 2021.
developing topic disclosures for biodiversity, building on the existing topic disclosures (alongwith their related reporting requirements, recommendations, and guidance) including:o revising the existing content;o developing new disclosures, requirements, recommendations, and guidance toaddress areas not currently covered by the Standard.
revising and updating the existing Bibliography related to biodiversity.
revising existing definitions in the GRI Standards Glossary and, where applicable, developing
new ones.
identifying which GRI Sector Standards content related to biodiversity should be revised toensure alignment and consistency with the revised Topic Standard for Biodiversity.

A multi-stakeholder technical committee of 18 experts representing all five GRI constituencies wasappointed by the GSSB in November 2021. The technical committee informed the revision of theStandard by convening throughout 2021-2023 in 10 meetings.

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Scope of the public comment

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The Biodiversity Standard exposure draft was open for public comment, as required by the GSSB
Due Process Protocol, from 5 December 2022 to 28 February 2023.

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Respondents were invited to submit their feedback on the clarity, feasibility, and relevance of thesignificant proposals contained in the exposure draft.

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Several outreach activities were carried out during the public comment period, including webinars,
regional workshops, and one-to-one consultations with stakeholders. 400 participants attended theregional workshops, online or in-person, in Africa and Latin America. Approximately 1,650 individuals
attended the global webinars. In addition, GRI participated in three events at COP 15. Appendix 1
contains an overview of these events.

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Comments collected during PCP activities such as workshops or webinars, though not considered
official public comment submissions, were also taken into account when they aided understanding of
the official submissions or flagged a significant issue that was not raised in the official submissions.

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Overview of participation in public comment

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Respondents were invited to submit their comments on the Biodiversity Standard exposure draft using
an online survey. The link to the survey was made available on the Biodiversity project page.
Respondents could also submit an official letter or statement to biodiversity@globalreporting.org.

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A total of 122 submissions from individuals and organizations were received, consisting of 103
completed surveys and 19 letters. The submissions contained approximately 1,800 comments. See
Figure 1 and Figure 2 for a breakdown of submissions by stakeholder constituency and region.
Submissions were received from all five stakeholder constituencies represented by the GSSB:
business enterprises, civil society organizations, investment institutions, labor, and mediating
institutions. Submissions were received from 38 countries across five continents.

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Figures 1 and 2. Breakdown of all submissions received by constituency and geographic region

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A second comment period was opened for a re-exposure of draft Disclosure 304-7 Access andbenefit-sharing, between 26 July and 10 September 2023. This was due to significant changes madeafter the PCP in the draft Standard. An additional 17 submissions from individuals and organizations
were received. See Figure 3 and Figure 4 for a breakdown of submissions by stakeholder
constituency and region.

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Figures 3 and 4. Breakdown of submissions received for re-exposure of draft Disclosure 304-7
Access and benefit-sharing, by constituency and geographic region

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For more details on the submissions received, see:

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Full set of comments on the Biodiversity project page.
Appendix 2 for an overview of respondents.

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Methodology for analyzing comments

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All comments submitted by respondents were collated by the Standards Division.

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Each comment was categorized according to its relevance to a specific Standard, section, disclosure,or a group of disclosures in the Biodiversity exposure draft, or as a cross-cutting theme. Eachcomment was then sub-categorized by the respondent’s:

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support for proposed content, based on its clarity, feasibility, and relevance to reporting;

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opposition to the proposed content, based on its clarity, feasibility, and relevance toreporting;

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concern about the proposed content, based on its clarity, feasibility, and relevance toreporting;114•

proposals for new content.

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When a respondent had raised several, different points in one comment, the points were separated
into distinct comments.

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Comments that could not be adequately summarized or interpreted are presented in this summary,where relevant, verbatim inside quotation marks.

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The qualifiers indicated in Table 1 have been used to indicate the percentage of respondents thatprovided feedback on a significant issue. Given that the survey mostly contained open questions toenable respondents to provide feedback on sections of interest, not all respondents provided
comments on all sections of the exposure draft. Consequently, certain sections or disclosures have arelatively low number of comments compared to the overall number of respondents.

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Table 1. Qualifiers indicating the percentage of respondents that provided feedback.
QualifierRespondents

Majority

> 50%

Many

30-50%

Some

10-30%

A few

< 10%

One

1

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Significant issues and GSSB

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responses

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In line with the GSSB Due Process Protocol, this section summarizes the significant issues raised byrespondents, outlines proposed changes to the Biodiversity Standard exposure draft, and explains thereasons why significant changes recommended by respondents were, or were not, accepted by the
GSSB.

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The significant issues identified have been organized into the following sections:132•

Cross-cutting issues

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Issues by disclosure

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This section includes references to the Biodiversity Standard exposure draft, and the final version of
GRI 101: Biodiversity 2024. When referring to the content in the exposure draft, the titles in the
exposure draft are used. When referring to the content in the final Biodiversity Standard, the titles in
GRI 101: Biodiversity 2024 are used.

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Cross-cutting issues

139a) Focus on most significant impacts on biodiversity

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Many respondents raised concerns about the concept ‘most significant impacts’. These respondents
stated that:

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focusing on most significant impacts is subjective and may limit transparency in terms of thetotal footprint of the company;
additional guidance is needed to understand how to prioritize impacts;
organizations with no net loss or net gain commitments need to report on all impacts and,
therefore, all operational sites should be considered;
the term ‘material impacts’ should be used instead to align with other standards.

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One respondent welcomes the focus on the most significant impacts for reporting on the location ofoperational sites as reporting on impacts for all sites would be unduly burdensome.

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GSSB response:

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The reference to ‘most significant impacts’ is maintained. Two reporting options are included
in requirements 101-5-b and 101-5-d in the final Standard to report the percentage of
operational sites in or near ecologically sensitive areas and the proportion of total high-impact

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commodities sourced respectively. These options can help provide a high-level understandingof the significance of biodiversity across the organization’s operations and its supply chain.
The requirement to explain how operational sites and products and services in the supply
chain with the most significant impacts on biodiversity have been determined has been
separated in a new disclosure (Disclosure 101-4 in the final Standard). This disclosure
provides more detailed guidance on the criteria that organizations can consider to identify
their most significant impacts on biodiversity, including the direct drivers of biodiversity loss,
the proximity to ecologically sensitive areas, and the changes to the state of biodiversity. The
guidance also provides more information on the type of data and the tools that can be used.
It has been clarified that it is up to the organization to set the threshold to determine which
operational sites and which products and services in its supply chain have the most significant
impacts on biodiversity and that an organization, for example, can determine that all of its
operational sites have the most significant impacts on biodiversity, except for its
headquarters.
No changes have been made to the term ‘most significant impacts’ as it is aligned with how
impacts are described in GRI 3: Material Topics 2021.

170b) Reporting on supply chain impacts

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Many respondents raised that reporting on supply chain impacts, especially beyond the first tier, ischallenging. Respondents stated that:• reporting on impacts along the supply chain is important but it is difficult to obtain data fromsuppliers beyond the first tier and it increases the burden on suppliers to provide thenecessary data;• reporting the information on suppliers’ impacts (i.e., information on the condition of
ecosystems, and on the ecosystem services and beneficiaries) is challenging and there is nowell-established methodology to measure suppliers’ impacts. It is suggested that theserequirements should be removed or revised to adopt a qualitative approach;• it is challenging to obtain information on the actions taken by suppliers to manage theirimpacts.

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GSSB response:

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Reporting on supply chain impacts is maintained in the Standard and requirements have beenrevised following public feedback.
The reference to ‘suppliers’ operational sites’ has been changed to ‘products and services in
its supply chain’ in the final Standard. Instead of reporting information for suppliers’
operational sites, the information is now reported for each product and service in the supply
chain with the most significant impacts on biodiversity.
o Disclosure 101-4 requires information on how products and services in the supply
chain with the most significant impacts on biodiversity have been determined.
o Disclosure 101-5 requires information on the countries and jurisdictions of products
and services in its supply chain with the most significant impacts on biodiversity.
o Disclosure 101-6 requires information on the direct drivers of biodiversity loss
associated with these products and services.
Requirement 304-3-c to report the condition of ecosystems that are or could be affected bysuppliers’ activities has been changed to a recommendation in Disclosure 101-7 in the final
Standard. Similarly, requirement 304-4-b to report the significant ecosystem services andbeneficiaries that are or could be affected by suppliers’ activities has been changed to a
recommendation in Disclosure 101-8 in the final Standard.
It has been clarified in the guidance of Disclosure 101-2 in the final Standard that the
management of biodiversity impacts only covers actions taken by the organization to manage
impacts in its supply chain and does not cover actions taken by the suppliers themselves.

203c) Site-level reporting

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Some respondents indicated that reporting site-level information is feasible. A few respondents
indicated that site-level information is challenging to report. These respondents stated that it isparticularly challenging to identify suppliers’ operational sites.

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GSSB response: The Biodiversity Standard exposure draft only requires reporting the country or
jurisdiction where the suppliers’ activities are located, not the exact location or coordinates of theirPage 7 of 24

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operational sites. The reference to ‘suppliers’ operational sites’ has been changed to ‘products andservices in its supply chain’ in the final Standard. Instead of reporting information for each country or
jurisdiction where the suppliers’ operational sites are located, the information is now reported for eachproduct and service in the supply chain with the most significant impacts on biodiversity.

213d) Interoperability with TNFD

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A few respondents indicated that the use of the Taskforce on Nature-related Financial Disclosures(TNFD) beta framework enables the reporting using the GRI Biodiversity Standard exposure draft. A
few respondents indicated that they were not yet able to assess the interoperability between the
TNFD framework and the GRI Biodiversity Standard exposure draft. A few respondents indicated that
dependencies should also be covered by the GRI Biodiversity Standard. A few respondents
welcomed the intent to align to the extent possible.

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GSSB response: The final TNFD framework was published during the revision of the GRI Biodiversity
Standard exposure draft. Efforts were made to ensure alignment to the greatest extent possible. This
includes alignment with TNFD’s ecologically sensitive locations and recommended disclosures andmetrics. It should be noted, however, that the scope of the TNFD is broader as it covers nature, andnot solely biodiversity. No further changes were made to include dependencies, which are notcovered by the GRI Standards.

226e) Positive impacts

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A few respondents stated that reporting on positive actions and impacts to promote biodiversity
should be included.

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GSSB responses: No further changes were made. Disclosure 304-5 Management of biodiversityrelated impacts (Disclosure 101-2 in the final Standard) already enabled organizations to report on
additional conservation actions that aim to have a positive impact on biodiversity and are not related
to the management of their negative impacts. Disclosure 304-5 also enabled organizations to reporton transformative actions that also aim to generate positive impacts on biodiversity.

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Issues by disclosure

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Disclosure 304-1 Location of operational sites with the mostsignificant impacts (Disclosures 101-4 and 101-5 in the final
Standard)

238a) Reporting on area of influence

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A few respondents suggested that the guidance on how to determine an organization’s area ofinfluence is unclear and should include a threshold or a range. One respondent noted that the area ofinfluence may be defined in national legislation. A couple of respondents also noted that further clarity
is needed for the term ‘near’.

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GSSB response: The guidance has been revised. The organization can use a radius if it cannot
identify the area affected or potentially affected by its activities. If the organization uses a radius, it
should explain this and report the distance of the radius used. No threshold has been included in theguidance. The area of influence varies according to the type of activities conducted and the type of
ecosystems and species affected or potentially affected. It is, therefore, not possible to establish a
fixed threshold or range for all organizations.

249b) Area of high biodiversity value is too subjective

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A few respondents noted that the term ‘area of high biodiversity value’ is unclear. These respondents
stated that it is not clear if it refers to economic value or value to conservation and noted that the term
should be clearly defined.

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A couple of respondents suggested changing the term ‘area of high biodiversity value’ to ‘area of highbiodiversity importance’ to align with the language in Target 1 of the Global Biodiversity Framework.

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A few respondents indicated that the criteria for areas of high biodiversity value are unclear. One
respondent suggested to ‘separate out methods that have criteria to identify sites of importance forbiodiversity (e.g. HCV, Important Plant Areas, IBAs, IMMAs, ISRAs, etc) from corridors, OECMs,
critical habitats which are more about ways of managing the sites’. A couple of respondentssuggested additional categories could be included (e.g., previously legally protected areas,
threatened ecosystems).

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GSSB response: The requirements and guidance of this disclosure have been revised to align with
the Taskforce on Nature-related Financial Disclosures (TNFD). ‘Ecologically sensitive area’ replaces‘area of high biodiversity value’. Ecologically sensitive areas (referred to as ‘ecologically sensitive
locations’ or ‘sensitive locations’ in the TNFD framework) are defined as areas meeting at least one of
the following criteria, in line with the TNFD:• Areas of biodiversity importance;• Areas of high ecosystem integrity;• Areas of rapid decline in ecosystem integrity;• Areas of high physical water risks;• Areas important for the delivery of ecosystem service benefits to stakeholders.

271c) Data confidentiality

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A few respondents raised concerns about the disclosure of site coordinates for their operations andtheir suppliers. These respondents stated that it is confidential or sensitive operational andcommercial information, and that it has no environmental value.

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GSSB response: The requirement to report the coordinates of the organization’s operational sites has
been changed to a reporting option. The Biodiversity Standard exposure draft did not require reportingthe coordinates of suppliers’ operational sites, only the country or jurisdiction. Reporting the country or
jurisdiction for suppliers is maintained. It is now required to be reported for products and services inthe supply chain and no longer for the suppliers’ operational sites.

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Disclosure 304-2 Direct drivers of biodiversity loss (Disclosure 1016 in the final Standard)

282a) Identification and reporting of direct drivers

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Some respondents raised concerns, or required clarification, on the type of data and tools that can beused to report on the direct drivers of biodiversity loss. These respondents stated that:

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additional guidance on how to determine which direct drivers should be reported is needed,suggesting tools such as ENCORE and the Science Based Targets for Nature (SBTN) tools;
the guidance on the type of data that can be used to report information for the supply chain is
unclear;the disclosure should be more specific about which metrics and tools to use to standardize
the data reported and to ease comparability. One respondent recommended to report
additional quantitative data on the production of goods or services, energy and water
consumption, effluents generation, non-GHG atmospheric emissions and solid waste volume,
type and destination (at least), separated for each location;
there is a lack of impact measurement standards on the five direct drivers of biodiversity loss
and that the quantification of direct drivers will take time and resources and the reliance uponmodeled data can lead to greenwashing.

GSSB response:•••

Disclosure 101-4 in the final Standard provides more detailed guidance on the criteria that anorganization can consider to identify its most significant impacts on biodiversity, including how
it can use the ENCORE and SBTN tools to identify which direct drivers should be reported.
The guidance has been revised to clarify how to report information on the direct drivers for
products and services in the supply chain with the most significant impacts on biodiversity(requirements 101-6-e and 101-6-f in the final Standard), including examples of tools that canbe used.
Requirements 304-2-d and 304-2-e in the Biodiversity Standard exposure draft (requirements
101-6-b and 101-6-c in the final Standard) to report the type and quantity of resources used

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and the type and quantity of pollutants generated have been maintained. The resources used
and the pollutants generated vary according to the type of activities. It is, therefore, notpossible to specify the natural resources and pollutants that are relevant for all organizations.
Note that ‘resources used’ has been changed to ‘wild species harvested’ in requirement 1016-b in the final Standard.
The guidance to requirement 304-2-g in the Biodiversity Standard exposure draft(requirement 101-6-f in the final Standard) has been revised to explain that an organization
should use primary data. However, if this data is unavailable, an organization can use
secondary or modeled data to obtain the required information. Although less accurate,
information based on secondary or modeled data can provide useful insights to support anorganization’s management of its impacts. A recommendation has been included to reportwhich information draws on primary, secondary, or modeled data and whether theorganization plans to improve the accuracy of the data.

320b) Climate change

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A few respondents raised concerns about reporting on greenhouse gas emissions. Respondents
stated that:

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it is not necessary as they are already reported under GRI 305: Emissions 2016;it may be challenging to report Scope 3 emissions;
it is difficult to link greenhouse gas emissions to specific biodiversity impacts.

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GSSB response: The requirement to report Scope 1, Scope 2, and Scope 3 greenhouse gas
emissions has been removed. The reference to climate change as one of the direct drivers of
biodiversity loss remains in the guidance of Disclosure 101-6 in the final Standard. The guidance also
explains that an organization can report its greenhouse gas emissions using GRI 305: Emissions
2016.

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c) Land and sea use change

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Some respondents commented on the requirement to report land and sea use change. These
respondents requested clarification or additional information, and stated that:• reporting on the conversion of modified ecosystems should be a requirement instead of arecommendation;• the term ‘cut-off date’ should be clarified as well as the time period that should be accounted
for when reporting on ecosystem conversion, and examples should be provided to increase
comparability of reporting;• a single ecosystem classification should be recommended to report ecosystem conversion,suggesting the classification from the UN System of Environmental Economic Accounting (UNSEEA) as it is used in the European Sustainability Reporting Standard on Biodiversity andecosystems;• the term ‘land and sea use change’ should be replaced by ‘natural ecosystem conversion’ orby ‘land, freshwater and sea use change’.

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One respondent indicated that organizations should also report their ‘land use’, which combines
information on land cover and management intensity, and the threat status of the ecosystem.

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GSSB response:

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The recommendation to report the type and size of modified ecosystems converted is now arequirement. See requirement 101-6-a-ii in the final Standard.
The guidance on cut-off date and reference date has been clarified, including to explain thetime period that should be accounted for when reporting on ecosystem conversion.
The Biodiversity Standard exposure draft included a reference to the IUCN Global Ecosystem
Typology (GET) that can be used to report the type of ecosystems. A footnote has been
included in the final Standard to clarify that the UN SEEA and TNFD use classifications thatare aligned with the IUCN GET.
The name of the direct driver remains ‘land and sea use change’, in line with the IPBESGlobal Assessment report. The guidance has been clarified to explain that this direct driver
covers terrestrial, freshwater, and marine ecosystems.

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•

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Land use is not included in addition or instead of ecosystem conversion as it is different fromthe direct driver of land use change. Impacts resulting from land use, such as intensification ofpractices, are captured under the changes to the state of biodiversity in Disclosure 101-7.

362d) Overexploitation of resources

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A few respondents commented on the requirement to report overexploitation of resources. These
respondents stated that the terms ‘overexploitation’ and ‘sustainable levels’ were unclear and need to
be defined. One respondent indicated that it should be clarified that this direct driver covers wild
species only, and not domesticated species such as crops.

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GSSB response: The direct driver of overexploitation of resources has been revised. It has beenclarified that this direct driver refers to the exploitation of natural resources and information needs tobe reported when the organization’s exploitation of natural resources leads to its most significant
impacts on biodiversity. Furthermore, it has been clarified that the requirement covers wild species.

371e) Pollution

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A few respondents raised concerns that quantifying light and noise pollution is not feasible.

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GSSB response: The recommendations to report the decibels above the normal level and theduration of noise produced, and the lumens and duration of light produced have been revised toreport instances that do not comply with legal requirements for permitted pollution levels.

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f)

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A few respondents commented on the requirement to report on invasive alien species. These
respondents suggested to include guidance on authoritative references to identify invasive alien
species.

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GSSB response: The guidance has been revised to include a reference to national regulations and to
the Global Invasive Species Database and Global Register of Introduced and Invasive Species.

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Disclosure 304-3 State of biodiversity (Disclosure 101-7 in the final
Standard)384a) Causal link between an organization’s activities and changes to the state of biodiversity

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A few respondents raised concerns that attributing changes to the state of biodiversity to the activities
of one organization is not possible, because organizations are located in areas with different activities
that also contribute to the impacts. Changes in the state of biodiversity are the result of the cumulative
impacts of all those present within an area.

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GSSB response: The guidance to Disclosure 101-7 in the final Standard has been clarified to explainthat changes in the state of biodiversity may reflect the cumulative impacts of the organization's
activities and the activities of others. However, this information, together with information on directdrivers of biodiversity loss, helps to understand the organization’s impacts on biodiversity and caninform the management of these impacts.

394b) Reporting on affected ecosystems

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399

Some respondents commented on the requirement to report the condition of affected ecosystems.
These respondents stated that it is challenging to measure and that additional guidance on how todefine and measure ecosystem condition is needed. One respondent indicated that the mostchallenging aspect is to find the appropriate methods as it will depend on the unique circumstances ofa site (e.g., type of activities and ecosystems).

400
401
402
403

GSSB response: The guidance to Disclosure 101-7 in the final Standard has been revised to clarify
the methods that can be used to measure ecosystem condition. The guidance draws on recent
technical guidance that was published after the public comment period for the Biodiversity Standard
exposure draft.

404c) Reporting on affected species

405
406

Some respondents commented on the criteria to identify the species that should be included in thereporting. They indicated that it is difficult to assess species that are sensitive to an organization’s

Invasive alien species

Page 11 of 24

407
408

activities and those that play a ‘critical role in the ecosystem’. They also suggested clarifications to thelist of criteria. One respondent suggested to require information for all species affected.

409
410
411

A few respondents commented on the option to report the species population size, raising concerns
about the feasibility to report this information. One respondent supported the guidance on proxy
indicators, indicating it provides a fair approach to reporting on population size.

412
413
414

GSSB response: Given the challenge to assess affected species, the requirements to report the
species name and extinction risk have been changed to a recommendation. The option to report the
species population size has been maintained.

415d) Baseline information

416
417
418

A few respondents commented that the guidance on baseline was unclear. These respondents statedthat additional guidance on how to set the baseline and base year is needed, and that the concepts ofbaseline and reference condition are mixed up.

419
420
421
422

GSSB response: The guidance has been revised to include references to best practices to conductbaseline studies, and to clarify the distinction between reference condition and baseline: a reference
condition is used to calibrate the measurement of ecosystem condition over time, and it differs from abaseline which is the condition of the ecosystem for the base year.

423
424

Disclosure 304-4 Ecosystem services (Disclosure 101-8 in the final
Standard)

425a) Identifying ecosystem services

426
427
428
429

A few respondents raised concerns about the feasibility to identify and report ecosystem services.
There respondents mentioned it requires biodiversity expert level skills and one respondent also
noted that it may be difficult to identify ecosystem services when there is no dependency on theecosystem service.

430
431
432

A few respondents suggested requesting information about the method or tool used to identify
ecosystem services and their beneficiaries, any prioritization (significant versus non-significant), andassumptions made.

433
434
435
436
437
438
439
440
441

GSSB response: The requirement to report the ecosystem services and beneficiaries affected or
potentially affected by the organization’s activities has been maintained. Given the complexity toreport supply chain related impacts, the requirement to report the ecosystem services andbeneficiaries affected or potentially affected by suppliers’ activities has been removed. In addition, theguidance has been revised to include additional tools and resources to identify ecosystem services,
including the Natural Capital Protocol from the Natural Capital Coalition and the Corporate Ecosystem
Services Review from the World Resources Institute. Finally, a reporting option has been included to
explain if the organization engages with stakeholders to identify the ecosystem services andbeneficiaries affected.

442b) Significant ecosystem services

443
444
445
446

A few respondents noted that the term ‘significant ecosystem services’ is unclear and that there is no
guidance on how to identify significant ecosystem services. A few respondents suggested clarifyingthat the organization is required to list all the ecosystem services that could be affected but explain
the most prominent ones.

447
448
449
450

GSSB response: The disclosure has been revised to focus on reporting the ecosystem services thatare or could be affected as a result of the organization’s most significant impacts, rather thanreporting the significant ecosystem services. A recommendation has been included to describe theapproach used to identify the ecosystem services reported.

451c) Dependencies

452
453

A few respondents noted that the disclosure may benefit from including a section on dependencies to
get a complete picture of the state of nature and risks related to ecosystem services.

454
455

GSSB response: No changes were made. The GRI Standards are the only global standards with an
exclusive focus on impact reporting for a multi-stakeholder audience. The Biodiversity Standard

Page 12 of 24

456
457

exposure draft focuses on the impacts an organization has on biodiversity. The dependencies on
biodiversity are important to understand how an organization is affected by biodiversity loss.

458
459

Disclosure 304-5 Management of biodiversity-related impacts(Disclosure 101-2 in the final Standard)

460a) Mitigation hierarchy

461
462

A few respondents commented on the relevance of using the mitigation hierarchy to report the
management of impacts. These respondents stated that:

463
464
465
466
467
468
469
470
471
472
473
474
475
476

•
•
•

the mitigation hierarchy may not be applicable to all sectors and suggested to facilitate
reporting on other impact measurement methodologies;
it may not be relevant to report actions for each stage of the mitigation hierarchy given that itis project- and location-specific. Instead, it was suggested to report the commitment to themitigation hierarchy and the mechanisms to ensure its rigorous application;
it is important to stress that this is a hierarchy of steps and that the steps are to be taken in
the mentioned order.

GSSB response:••

Reporting on the management of biodiversity impacts using the mitigation hierarchy has been
maintained. The mitigation hierarchy is a well-established and recognized approach which isused across different sectors.
The Biodiversity Standard exposure draft already mentioned that the mitigation hierarchy
consists of a hierarchy of steps to be taken in a specific order and, therefore, no changes
were made to that guidance.

477b) Restoration

478
479

A few respondents commented on the requirement to report ecosystem restoration. These
respondents stated that:

480
481
482
483
484
485
486
487
488
489
490
491
492
493
494
495
496
497
498
499
500
501
502
503
504
505

•
•
•
•
•

information on the quality of the ecosystem after restoration and whether it is restored to thesame or a similar situation before the organization’s activities should be reported;
it may be meaningful to include indicators that measure restoration activities, includingchanging the recommendation to a requirement to report the ratio of area restored to the area
affected;
it may be meaningful to have sub-indicators for the different stages of restoration, as highquality restoration takes a long time and to encourage progressive restoration;
the definition of area restored is unclear and should take into account situations where
restoration or closure criteria are defined through community and other stakeholder
engagement and endorsed by the regulator or governing agency;
restoration and rehabilitation should be differentiated.

GSSB response:
•
•

•
•

•

The requirement to report actions taken to restore affected ecosystems has been revised toinclude reporting the goals of the restoration and rehabilitation.
The recommendation to report the size of the area restored has been changed to arequirement and has been expanded with a new requirement to report the size of the area
under restoration or rehabilitation. New guidance has been provided on how that information
can be compared to information reported under other disclosures. This new guidance
replaces the recommendation to report the ratio of the area restored to the area affected.
The guidance has been revised to include a recommendation to report the stage of theorganization’s restoration and rehabilitation actions.
The guidance has been revised to clarify the definitions of restoration and rehabilitation. The
requirement to report actions taken to restore affected ecosystems has been revised toinclude reporting how stakeholders are engaged throughout the restoration and rehabilitation
actions.
The requirements in the final Standard distinguish restoration from rehabilitation.

Page 13 of 24

506c) Offsets

507
508

A few respondents raised concerns about the inclusion of reporting on offsets. These respondents
stated that:
•
•

509
510
511
512
513
514
515

•

biodiversity offsets are controversial and reporting on them can lead to greenwashing;
the disclosure should include criteria for what is considered sustainable offsets, and an
explanation of why offsets were used instead of alternative measures;the disclosure could include additional information such as the offset purpose, type, area,
phase, delivery deadline, project targets, and associated co-benefits.

GSSB response: A new requirement has been included to report additional information for each offset
so that information users can assess the quality of the offset. The additional information includes:
•
•
•

516
517
518
519
520

•

the goals;
the geographical location;
whether and how principles of good offset practices are met (e.g., additionality, ecologicalequivalence, and permanence);
whether and how the offsets are certified or verified by a third party.

521d) Progress

522
523
524
525
526
527
528

A few respondents provided comments related to progress. A few respondents said that the results of
the actions should be reported and one of those respondents further explained that it is important toknow the scale or extent of those actions, for example, if ‘avoidance’ is very small in scale or extent
while actions lower in the mitigation hierarchy, such as ‘offsets’, are much larger in scale or extent.
Finally, one respondent mentioned that there is no clear guidance on the metrics to use andsuggested using condition adjusted surface area, as in Disclosure 304-3, to understand whether
mitigation actions positively affect the changes in the state of biodiversity.

529

GSSB response:
•

530
531
532
533
534

•

The requirement for restoration and rehabilitation asks for the total size of the area underrestoration and rehabilitation, and area restored and rehabilitated. This can be used tomeasure progress of restoration actions over time.
A requirement to report the goals of offsets has been added. An option to report the delivered
outcomes in the case an offset has been finalized has been included in the guidance.

535e) Biodiversity management plans

536
537
538
539
540
541

A few respondents commented on the requirement to report the percentage of sites with the mostsignificant impacts on biodiversity with management plans. These respondents stated that it is notclear how to calculate the percentage of sites with management plans, which actions it refers to, andif it covers plans that have already been implemented or if it also covers future plans. One respondent
indicated that, for investors, it would be helpful to know the sites where actions have been taken andthe sites where no actions have been taken, and why.

542
543
544
545
546

GSSB response: Requirement 304-5-b in the Biodiversity Standard exposure draft (requirement 1012-d in the final Standard) has been revised to list which of the operational sites with the mostsignificant impacts on biodiversity have a biodiversity management plan and to explain why the otheroperational sites do not have a management plan. Guidance has been added to explain what
information is included in a biodiversity management plan.

547

f)

548
549

A few respondents commented on the requirement to report synergies and trade-offs between actions
taken to manage biodiversity impacts and climate change impacts. These respondents stated that:

550
551
552
553
554

Synergies and trade-offs•••

it should encompass other synergies and trade-offs (e.g., desertification);
it may be difficult to report as it is difficult to understand the connection between biodiversity
and climate change;a narrative approach to this requirement is appropriate.

GSSB response:

Page 14 of 24

555
556
557
558

•
•

The focus on biodiversity and climate change has been maintained, as this is where most of
the discussions are focused on and extending it to other topics will not be easy to report.
The requirement has been maintained, but an example has been added in the guidance toclarify the synergies between actions to manage biodiversity and climate change impacts.

559g) Downstream

560
561

One respondent asked how organizations that distribute products and services should report how
they allow their clients to manage their negative impacts.

562
563

GSSB response: The scope of the disclosure has been clarified by including a recommendation in theguidance to report actions taken to manage impacts in an organization’s downstream value chain.

564
565

Disclosure 304-6 Halting and reversing the loss of biodiversity(Disclosure 101-1 in the final Standard)

566a) Targets to halt and reverse biodiversity loss

567
568
569
570

A few respondents suggested additional guidance be provided to explain the concept of ‘sciencebased approach’ and how organizations can apply such an approach. A few respondents suggested it
may be helpful to also consider the need for organizations to monitor progress stemming from theirpolicies and commitments to halt and reverse the loss of biodiversity.

571
572
573
574
575
576
577
578
579

GSSB response: The term ‘science-based approach’ has been replaced by ‘scientific consensus’ toalign with the language used in the Sustainability context principle defined in GRI 1: Foundation 2021.
Guidance has been included to clarify that national biodiversity strategies and action plans developedin the context of the Convention on Biological Diversity, or independent assessments of the ecologicalstatus of an area can be used to inform goals and targets based on scientific consensus.
Recommendations have been added to report how the goals and targets are set, the baseline for thegoals and targets, and the timeline for achieving the goals and targets. An example has been includedin the guidance to clarify how to report progress toward the goals and targets, which is required to bereported for all goals and targets (see requirement 3-3-e-iii in GRI 3: Material Topics 2021).

580
581

Disclosure 304-7 Access and benefit-sharing (Disclosure 101-3 in
the final Standard)

582
583

Summary of public comments on the first exposure draft of the Standard, and
GSSB responses

584a) Unclear scope

585
586

A few respondents indicated that the scope of the disclosure is unclear. These respondents stated
that:

587
588
589
590
591
592
593
594
595

•
•
•
•
•

the concept of access and benefit-sharing (ABS) is unclear and more guidance is needed;
the number of ABS permits and agreements are not effective indicators of compliance, as
provider countries have varying legislations or measures in place to regulate ABS, including
no rules for ABS;the disclosure suggests that organizations should comply with ABS measures including injurisdictions where no relevant regulations exist;
patents are not directly covered under the scope of the Nagoya Protocol;that this weakens, rather than strengthens, the ABS Clearing-House, which is an official
public repository of all relevant information on ABS.

596
597

One respondent proposed to replace the requirements with a description of the internal compliancesystems and processes.

598
599
600
601

GSSB response: The requirements to report the number of ABS permits and ABS agreements havebeen replaced by new requirements to describe the process to ensure compliance with ABS
regulations and measures and voluntary actions taken in addition to or in absence of regulations andmeasures. The requirement related to patents for inventions based on or derived from the utilization

Page 15 of 24

602
603

of genetic resources or associated traditional knowledge has been removed. In the guidance it isexplained that information on ABS can be found through the ABS Clearing-House.

604b) Data confidentiality

605
606
607

A few respondents indicated that the information required to be reported is often confidential,
including the type and amounts of monetary and non-monetary benefits, how they are distributed toother stakeholders, and how they are monitored.

608
609
610
611
612
613

GSSB response: The requirements to report the type and amounts of monetary and non-monetary
benefits shared and to describe how they support Indigenous Peoples, local communities, and theconservation and sustainable use of biodiversity have been removed. The requirements in thedisclosure have been replaced by new requirements to describe the process to ensure compliancewith ABS regulations and measures and voluntary actions taken in addition to or in absence ofregulations and measures.

614
615

Summary of public comments on the second exposure draft of the Standard,and GSSB responses

616a) Clarity of the disclosure

617
618

A majority of respondents indicated that the second exposure draft was clear and understandable. It
is an improvement compared to the previous draft.

619b) Distinction between 304-7-a and 304-7-b

620
621

A majority of respondents indicated that the distinction between the process in requirement 304-7-aand the actions in requirement 304-7-b was not clear.

622

GSSB response: The guidance has been revised to clarify that:

623
624
625
626
627
628
629

•
•

the information required under 304-7-a (requirement 101-3-a in the final Standard) covers
instances where ABS regulations and measures are applicable to the organization;
the information required under 304-7-b (requirement 101-3-b in the final Standard) covers
instances where the organization takes voluntary actions to share the benefits arising fromthe use of genetic resources and associated traditional knowledge fairly and equitably when
there are no ABS regulations or measures, and instances where an organization takes
voluntary actions in addition to legal obligations.

630c) New agreement under the UN Convention on the Law of the Sea

631
632

One respondent indicated that in June 2023 a new agreement under the UN Convention on the Lawof the Sea (UNCLOS) was adopted. This agreement has clauses on access and benefit-sharing.

633

GSSB response:

634
635
636
637
638
639
640

•
•

Guidance has been added about the new agreement under the UNCLOS, as it covers accessand benefit-sharing of marine genetic resources located in areas beyond national jurisdiction.
The focus of the disclosure on access and benefit-sharing as mentioned in the Nagoya
Protocol has been maintained. The guidance has been revised to include a reference to the
new agreement under the UNCLOS and, if an organization has activities on the sea beyond
national jurisdiction, an option to report if it implements processes and actions to ensure
access and fair and equitable benefit sharing of marine genetic resources.

Page 16 of 24

641

Appendix 1. Participation to regional

642

events and webinars

643

Table 2: Overview of events and webinars
EventsDate

Number of attendees

COP 15 - Nature is the new climate: What
does this mean for your organization?

14 December 2022

N/A

COP 15 - Business and biodiversity: Theessential role of global sustainability
reporting standards and their impact on
corporate decision making

14 December 2022

N/A

COP 15 - From A to Z with regulators,
standard-setters and framework bodies

15 December 2022

N/A

Global webinar – morning session

15 December 2022

431 registrations,
220 attendees

Global webinar – afternoon session

15 December 2022

330 registrations,
151 attendees

Global Q&A webinar – morning session

18 January 2023

1219 registrations,484 attendees

Global Q&A webinar – afternoon session

18 January 2023

828 registrations,345 attendees

Global Q&A webinar – morning session

16 February 2023

1369 registrations,523 attendees

Global Q&A webinar – afternoon session

16 February 2023

941 registrations,355 attendees

Webinar for Latin America (in Spanish)

7 February 2023

203

Webinar for Latin America (in Portuguese)

8 February 2023

155

Webinar for Africa

14 February 2023

42

Total

2054

644

Page 17 of 24

645

Appendix 2. Public comment

646

submissions by stakeholder

647

constituency, and region

648

Table 3: Overview of the public comment respondents for the draft Biodiversity Standard

Representation

Name

RegionStakeholder
constituency1

Individual

Abby Cho & Anthony Cheung

Asia

Investment institution

Individual

Lee Roberts & Ahmed Elamer

EuropeMediating institution

Organizational

Global Cement and Concrete
Association

EuropeBusiness enterprise*

Individual

Abulgasem ISSA

Middle EastMediating institution

Individual

Ahmet Birsel

EuropeMediating institution

Individual

Andrew Plumptre & Monica
Eisenberg

North America

Civil society organization

Organizational

IpiecaEuropeBusiness enterprise*

Individual

Beatriz Lombarde de Moraes

Latin America

Business enterprise

Individual

Bella Anis

Asia

Business enterprise

Individual

Bianca Nijhof

EuropeBusiness enterprise

Organizational

DOF Subsea

Oceania

Business enterprise

Organizational

Hog Watch Manitoba

North America

Civil society organization

Organizational

The Biodiversity Consultancy

EuropeBusiness enterprise

Individual

CA RAKESH CHOUDHARY

AsiaMediating Institution*

Individual

Cara MacMillan

North America

Mediating institution

Individual

Caroline Grassl

Latin America

Mediating institution*

1 Stakeholder constituencies marked by an asterisk have been reclassified from the option marked byrespondents in the PCP questionnaire, which included more granular options (Academic / Assurance provider /Business / Consultant / Government / Investor / Labor representative / Market regulator / Non-governmentorganization / Rating agency / Standard setter / Stock exchange / Student / Trade or industry association / Other)

Page 18 of 24

Individual

Clare Ho

Asia

Investment institution

Organizational

Pure Strategies

North America

Mediating institution

Organizational

WWF-US

North America

Civil society organization

Individual

Dadan Firdaus

Asia

Mediating institution

Organizational

MRV Collective

North America

Civil society organization

Organizational

Quantum Energy, Inc.

North America

Business enterprise

IndividualDavid Hernan Tardini

EuropeBusiness enterprise

Organizational

I CareLatin America

Mediating institution

Individual

ElenaBAKUN

EuropeBusiness enterprise

Organizational

Deakin University, IUCN Commission
on Ecosystem Management

Oceania

Mediating institution

Individual

Farheen Khanum

Middle East

Business enterprise

Organizational

IUCN

EuropeCivil society organization*

Organizational

The Endangered Wildlife Trust

AfricaCivil society organization

Individual

GABRIEL Sarasin

North America

Business enterprise

Organizational

Morningstar Sustainalytics

EuropeMediating institution

Organizational

Accountability Counsel

North America

Civil society organization

Organizational

Bayer AG

EuropeBusiness enterprise

Individual

Heather Elgar

EuropeCivil society organization

Individual

Hernando Echeverri

EuropeMediating institution

Individual

Igor Bubeník

EuropeBusiness enterprise

Individual

Ines Garcia

North America

Business enterprise

Organizational

The Instituto de Pesquisa Ambiental
da Amazônia (IPAM) [Amazon
Environmental Research Institute]

Latin America

Civil society organization*

Individual

Jacobo Correa

Latin America

Business enterprise

IndividualJames LEE

North America

Business enterprise

Individual

Jesus Antonio Mena Rodriguez

Latin America

Mediating institution*

Page 19 of 24

Individual

Jinsong Yang

Asia

Mediating institution*

Organizational

International Air Transport
Association

EuropeBusiness enterprise*

Organizational

INEGI

Latin America

Mediating institution*

Organizational

REPSOL

EuropeBusiness enterprise

Organizational

EcoVadis

EuropeMediating institution*

Individual

Julian Nugroho

Asia

Business enterprise

Individual

Junji Ban

Asia

Mediating institution

Individual

Jyh-Horng Lin

Asia

Mediating institution

Organizational

actE.Pte.Ltd

Asia

Investment institution*

Organizational

Ceres

North America

Civil society organization

Individual

Kathleen Buckingham

North America

Business enterprise

Individual

National Indian Carbon Coalition

North America

Civil society organization*

Individual

Kenechukwu Onukwube

AfricaCivil society organization

Organizational

Ekama Development Foundation

AfricaCivil society organization

Organizational

The Lake House Foundation

North America

Investment institution

Organizational

GBIF: Global Biodiversity Information
Facility

EuropeCivil society organization*

Individual

Laryssa Ron Esteves

Latin America

Business enterprise

Organizational

WWF France

EuropeCivil society organization

Organizational

Nokia

EuropeBusiness enterprise

Organizational

CSIR

AfricaMediating institution

Individual

Mafalda Evangelista

EuropeMediating institution

Organizational

South African National Biodiversity
Institute

AfricaMediating institution*

Organizational

Bâtirente

North America

Investment institution

Individual

Mario Keiling

EuropeMediating institution

Page 20 of 24

Organizational

European Bank for Reconstruction
and Development (EBRD)

EuropeInvestment institution

Individual

Martin Vaidiš

EuropeMediating institution

Organizational

RLAM

EuropeInvestment institution

Individual

Max Kolb

EuropeCivil society organization

Organizational

IUCN NL

EuropeCivil society organization

Organizational

NEI Investments

North America

Investment institution

Organizational

World Animal Protection

EuropeCivil society organization

Individual

MOLINA MOREJON VICTORMANUEL

Latin America

Mediating institution

Individual

Nabiha Megateli-Das

North America

Investment institution

Organizational

ISOS Group

North America

Mediating institution

Organizational

JEMA (The Japan Electrical
Manufactures’ Association), JEITA(Japan Electronics & Information
Technology Industries Association),
CIAJ (Communications andInformation Network Association ofJapan), JBMIA (Japan Business
Machine and Information System
Industries Association)

Asia

Business enterprise

Organizational

FEBEA

EuropeBusiness enterprise*

Organizational

IANSA

Latin America

Business enterprise

Individual

Olena Liakh

EuropeMediating institution

Individual

Olga Cam

EuropeMediating institution

Individual

Penny Lin

Asia

Business enterprise*

Individual

Peter Paap

EuropeMediating institution

Individual

Petra Westerlaan

EuropeMediating institution

Individual

Pinaki Dasgupta

Asia

Civil society organization

Individual

Praveen A

Asia

Mediating institution

Individual

Rachel Golden Kroner

North America

Mediating institution

Page 21 of 24

Individual

Rafael Silva

Latin America

Business enterprise

Individual

Rebekah Janzen

North America

Business enterprise

Individual

Rhonda Rudnitski

North America

Business enterprise

Organizational

the Hive - Changing the nature offinance

EuropeMediating institution

Individual

Sabine Müller

EuropeBusiness enterprise

Organizational

PLUSPETROL

Latin America

Business enterprise

Individual

Sanjay Molur

Asia

Civil society organization*

Individual

Sheila de Góis Nunes

Latin America

Labor organization

Individual

Silvia Siminelli

EuropeMediating institution*

Organizational

Agroasesorias de Colombia

Latin America

Business enterprise

Organizational

ITALIAN FOUNDATION FOR
BUSINESS REPORTING (O.I.B.R.)

EuropeCivil society organization

Organizational

Mastercube IoT LLP

AsiaBusiness enterprise

Organizational

New York City Comptroller

North America

Mediating institution*

Organizational

Natura &Co Latin America andNatura Cosmeticos organizations.

Latin America

Business enterprise

Individual

Tim Lamont

EuropeMediating institution

Organizational

UN Committee of Experts on
Environmental-Economic Accounting

North America

Mediating institution*

Organizational

ISA

Latin America

Business enterprise

Organizational

S&P Global Ratings

Latin America

Investment institution*

Individual

Wayne Morgan / Colin Semotiuk

North America

Mediating institution

Individual

Wendy Chong

Asia

Business enterprise

Organizational

DHI Water and Environment Inc.

North America

Mediating institution

Organizational

Technische Universität Dresden

EuropeMediating institution

Organizational

International Chamber of Commerce

EuropeBusiness enterprise*

Organizational

Dow

North America

Business enterprise

Organizational

BNP Parisbas

EuropeInvestment institution

Page 22 of 24

Organizational

CDC Biodiversité

EuropeInvestment institution

Organizational

World Benchmarking Alliance

EuropeMediating institution

Organizational

NBIM

EuropeInvestment institution

Organizational

Soluções Inclusivas Sustentáveis

Latin America

Civil society organization

Organizational

Evonik Industries

EuropeBusiness enterprise

Organizational

Association of British Insurers

EuropeInvestment institution

Organizational

ICMM

EuropeBusiness enterprise

Organizational

PwC

EuropeMediating institution

Organizational

CEBDS

Latin America

Business enterprise

Organizational

FAO

EuropeMediating institution

Organizational

Value Balancing Alliance

EuropeBusiness enterprise

Page 23 of 24

649

Table 4: Overview of the public comment respondents for the re-exposure of draft disclosure

650

304-7 Access and benefit-sharing

Representation

Name

RegionStakeholder
constituency2

Individual

Junji Ban

Asia

Mediating institution*

Individual

Emanuele Gemelli

EuropeBusiness enterprise*

Individual

André Francisco Pilon

Latin America

Mediating institution*

Individual

Jesuino Souza Araújo

Latin America

Mediating institution*

Organizational

ABA Fashions Ltd.

Asia

Business enterprise*

Organizational

Ekama Development Foundation

AfricaCivil society organization*

Individual

Natasha Tarampi

North America

Business enterprise*

Individual

Robert Blasiak

EuropeMediating institution*

Individual

Shelter Lotsu

AfricaMediating institution*

Organizational

TÜV SÜD Shanghai

Asia

Mediating institution*

Individual

Silvia Siminelli

EuropeMediating institution*

Organizational

National Institute of Statistics andGeography (INEGI)

Latin America

Organizational

World Animal Protection

EuropeOrganizational

International Chamber of Commerce(ICC)

EuropeOrganizational

GCB Cocoa

Asia

Business enterprise*

Organizational

Nizmonia

Asia

Business enterprise*Mediating institution*
Civil society organization*
Business enterprise*

2 Stakeholder constituencies marked by an asterisk have been reclassified from the option marked byrespondents in the PCP questionnaire, which included more granular options (Academic / Assurance provider /Business / Consultant / Government / Investor / Labor representative / Market regulator / Non-governmentorganization / Rating agency / Standard setter / Stock exchange / Student / Trade or industry association / Other)

Page 24 of 24